Governance & Program Info
Portfolio Management & Dynamic Allocation — Governance
Cross-builder institution context and per-item ownership, due dates, status, and next actions for the governance-relevant checklist items in this builder.
Institution context
Program info
Applies across every builder in the app. Stored locally; nothing leaves the browser.
Checklist governance
Items (0 of 17 marked complete)
Annotate ownership, due date, status, and next action. Items on the left come from the builder's governance / compliance phases.
05 · Governance & Compliance
Document fiduciary duty compliance under the Investment Advisers Act
AI recommendations must meet the same fiduciary standard as human recommendations — documented client-interest rationale per decision.
05 · Governance & Compliance
Track SEC AI-advisory guidance and enforcement patterns
The 2023 PDA rule was withdrawn but AI-washing enforcement (Delphia, Global Predictions 2024) is the operative regulatory signal.
05 · Governance & Compliance
Maintain Form ADV AI disclosure currency
"AI-powered" is a material disclosure requiring factual backing — updates required when the AI footprint changes materially.
05 · Governance & Compliance
Reg BI compliance for retail AI recommendations
Retail recommendations must meet Best Interest standard with documented care, skill, and prudence — audit-ready for SEC examination.
05 · Governance & Compliance
AI-washing substantiation review
Every external AI capability claim (marketing, Form ADV, client materials) traces to a measurable model behavior.
05 · Governance & Compliance
Classify system under EU AI Act Annex III
Portfolio AI serving EU retail clients falls under Annex III high-risk — triggering explicit logging, oversight, and transparency duties.
05 · Governance & Compliance
SFDR Article 6 / 8 / 9 classification per mandate
EU sustainable finance disclosure — the model's treatment of ESG data must match the SFDR classification the fund has declared.
05 · Governance & Compliance
ESMA performance advertising rule compliance review
ESMA rules govern performance presentation, benchmark choice, and AI capability claims — misleading comparisons are actionable.
05 · Governance & Compliance
IFRS S1/S2 (ISSB) sustainability disclosure alignment
ISSB standards became effective January 2024 — portfolio-level ESG reporting should align to the disclosure structure even where adoption is voluntary.
05 · Governance & Compliance
SR 11-7 model documentation package for the optimizer
Purpose, data lineage, assumptions, limitations, known failure modes, validation results — all seven SR 11-7 elements.
05 · Governance & Compliance
Independent model validation
Second-line or external team independent of development validates model logic, assumptions, and performance claims.
05 · Governance & Compliance
Ongoing performance monitoring plan
KPIs, monitoring cadence, alert thresholds, escalation path — documented and resourced under SR 11-7.
05 · Governance & Compliance
Change management and model versioning
Approval workflow, testing requirements, versioning, rollback, audit trail — every model change documented.
05 · Governance & Compliance
MRM coverage for the narrative generator
Narrative generator is a model under SR 11-7 — documentation, validation, and monitoring apply even though it generates text rather than allocations.
05 · Governance & Compliance
Board-level AI governance reporting
Portfolio AI performance, fair outcome metrics, AI-washing exposure, and regulator engagement should appear in board risk reporting.
05 · Governance & Compliance
Client-facing AI transparency disclosures
Clients served by AI-driven portfolio construction should receive plain-language disclosure of how AI is used and where humans decide.
05 · Governance & Compliance
Cross-border data transfer review
Client portfolio data flows must meet GDPR / UK GDPR / PIPL / DPDP / LGPD depending on jurisdiction — confirmed for every region served.